Current through May 1, 2026 · Last verified July 6, 2026
In one sentenceRule 2.104 sets out the three acceptable ways to prove that a summons and complaint were served in Michigan, and makes clear that failing to file that proof does not itself invalidate an otherwise proper service.
(1)written acknowledgment of the receipt of a summons and a copy of the complaint, dated and signed by the person to whom the service is directed or by a person authorized under these rules to receive the service of process;
(2)a certificate stating the facts of service, including the manner, time, date, and place of service, if service is made within the State of Michigan by
(a)a sheriff,
(b)a deputy sheriff or bailiff, if that officer holds office in the county in which the court issuing the process is held,
(c)an appointed court officer,
(d)an attorney for a party; or
(3)a written statement of the facts of service, verified under MCR 1.109(D)(3). The statement shall include the manner, time, date, and place of service, and indicate the process server's official capacity, if any. The place of service must be described by giving the address where the service was made or, if the service was not made at a particular address, by another description of the location.
(B)Failure to File. Failure to file proof of service does not affect the validity of the service.
(C)Publication, Posting, and Mailing. If the manner of service used requires sending a copy of the summons and complaint by mail, the party requesting issuance of the summons is responsible
for arranging the mailing and filing proof of service. Proof of publication, posting, and mailing under MCR 2.106 is governed by MCR 2.106(G).
Amendment History
Michigan tracks the orders that adopt and amend its Court Rules in a separate administrative record rather than printing a history note beneath each rule in the compiled rules text reproduced here. The text above is verified current through the source’s own May 1, 2026 update; for the full order-by-order history of this rule, see the Michigan Supreme Court’s rules and orders page.
Plain-English Summary
After service happens, someone has to tell the court it happened, and how. Rule 2.104 recognizes three ways to do that. First, the person served (or someone else authorized under the rules to accept service) can sign a dated, written acknowledgment of receipt. Second, if service was made in Michigan by a sheriff, deputy or bailiff, an appointed court officer, or an attorney for a party, that server can file a certificate describing the manner, time, date, and place of service. Third, anyone else who served process can file a written statement of those same facts, verified in the manner required for court filings generally, describing their official capacity if they have one and identifying where service took place.
Crucially, proof of service is a paperwork requirement, not a condition of valid service itself. If the proof is never filed, the underlying service is not automatically undone — subrule (B) says so directly. And when the method of service requires mailing a copy of the summons and complaint, it is the party who requested the summons who bears responsibility for arranging that mailing and filing the proof of it; the special proof requirements for publication, posting, and mailing under Rule 2.106 are handled under that rule's own terms.
Frequently Asked Questions
What are the accepted ways to prove service happened?
A signed, dated acknowledgment of receipt from the person served; a certificate of service from a sheriff, deputy, bailiff, appointed court officer, or attorney; or a verified written statement of the facts of service from anyone else who served process.
Does service become invalid if proof of service is never filed?
No. Rule 2.104 states directly that failing to file proof of service does not affect the validity of the underlying service.
Who is responsible for proving service when papers are mailed?
The party who requested issuance of the summons is responsible for arranging the mailing and for filing proof that it happened.
Source & verification. The rule text is reproduced verbatim from the
official Michigan Court Rules (MCR 2.104). Prescribed by the Supreme Court of Michigan (Mich. Const. 1963, art. VI, § 5). The plain-English summary is original and written by us. Last verified July 6, 2026. ·
Official source
Also known as:proof of service Michigancertificate of service requirementsacknowledgment of service